Raybo (Beijing) Technology Co., Ltd. (“Company”, “we”, “us”, or “our”) respects and protects the privacy of Users (“you”, “your” or “Users”). The Company will collect, use, disclose and process your Personal Information, in accordance with this Privacy Policy (“Policy”) when you:
(a) access or use our website and mobile applications (“Applications”) and services; and/or
(b) provide us with your Personal Information, regardless or the medium through which such Personal Information is provided.
The Company recommends that you shall carefully read and understand the whole contents of this Policy before your use of the Applications. Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the TronLink Terms of Service of the Company. If there is any discrepancy between the definitions of any defined term used in this Policy and the TronLink Terms of Service , the definition of any defined term used in this Policy shall prevail.
By providing us with your Personal Information, you consent to our collection, use, disclosure (including transfer) and processing of your Personal Information in accordance with this Policy. Please DO NOT provide any Personal Information to us if you do not accept this Policy.The Company reserves the right to update this Policy online from time to time, without notice to you, and the revised Policy will come into effect and supersede the older versions once posted on our Applications. The revised Policy will apply to Personal Information provided to us previously. In particular, if you do not accept the revised Policy, please immediately stop your use of the Applications. Your continuous use of our Applications will be regarded as your acceptance of the revised policy.
1.1 We collect your Personal Information, including but not limited to your mobile device information, operation records, transaction records and wallet addresses.
1.2 In order to satisfy your needs or requests for specific services, we may also collect Personal Information including but not limited to your name, bank card number, telephone number, email address etc.
1.3 You confirm that your Wallet Password, Private Key, Mnemonic Words, Keystore on the Applications are not stored or synchronized on the Company’ servers. The Company does not offer the service to recover your Wallet Password, Private Key, Mnemonic Words or Keystore.
1.4 We may also request for you to provide us with additional Personal Information in order for us to enable your use of any specific functions of the Applications. Your refusal to provide us with the requested Personal Information will be considered as your choice to not use a particular specific function of the Applications.
1.5 To the extent permitted by applicable laws and regulations, the Company may collect and use the Personal Information in the following circumstances without your prior consent or authorization:
1.5.1 information related to national security and national defense;
1.5.2 information related to public security, public health, significant public interests;
1.5.3 information related to criminal investigation, prosecution, trial and enforcement;
1.5.4 Personal Information in the public domain;
1.5.5 Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
1.5.6 Personal Information necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services; and/or
1.5.7 other circumstances permitted by laws and regulations.
1.6 We collect information in the following ways:
1.6.1 when you provide us with your Personal Information for whatever reasons;
1.6.2 when you authorize us to obtain your Personal Information from a third party;
1.6.3 when you register for a user account on our Applications;
1.6.4 when you contact us or interact with our employees through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
1.6.5 when you transact with us, contact us or request that we contact you;
1.6.6 when you request to be included in an email or our mailing list; and/or
1.6.7 when we copy all or part of your transaction records on the blockchain. However, you should refer to the blockchain system for your latest transaction records.
1.7 Our Applications may contain certain technologies that collect Personal Information in the manner described in this Policy (see paragraph 5 below) or the applicable terms and conditions.
1.8 Your provision of Personal Information to us is voluntary and you may withdraw your consent for us to use your Personal Information at any time. However, if you choose not to provide us with the Personal Information we require, it may not be possible for you to use the Applications or for us to contact you, or provide products or services which you need from us.
1.9 In certain circumstances, you may also provide us with the Personal Information of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her Personal Information and that he/she has consented to your disclosure of his/her Personal Information to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such Personal Information in accordance with the terms of this Policy.
1.10 You are responsible for ensuring that all Personal Information that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your Personal Information.
2.1 We collect, use or disclose your Personal Information for one or more of the following purposes:
2.1.1 to provide you with products and/or services that you request for;
2.1.2 to manage your relationship with us;
2.1.3 to facilitate your use of our Applications;
2.1.4 to associate you with your wallet by the unique serial number of your mobile device;
2.1.5 to push important notifications to you, such as software update, update of Terms of Service and this Policy;
2.1.6 to assist with your enquiries, feedback, complaints and requests by using the Wallet Address and the mobile device information provided by you;
2.1.7 to notify you of our products, services, programmes and events;
2.1.8 to resolve any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;
2.1.9 to conduct our internal audit, data analysis and research;
2.1.10 to conduct user behavior tracking by tracking the Users’ use of the Applications;
2.1.11 to comply with our obligations in accordance with laws, regulations and to cooperate with regulatory authorities;
2.1.12 to comply with international sanctions and applicable regulation for securities and to counter money-laundering or financing of terrorism;
2.1.13 to enforce obligations owed to us, and contractual terms and conditions; and/or
2.1.14 any other reasonable purposes related to the aforesaid.
2.3 We offer you the “Touch ID/Face ID” option in the “Settings” column of the TronLink to provide you with a convenient way to manage your digital Tokens.
2.4 We offer you the “Payment without Password” option in the TronLink. The Payment without Password function stores your Wallet Password in the Keychain/Keystore of your mobile devices via secure encryption algorithm. Your biological identification (Touch ID or Face ID) and authentication are called when conducting transactions, in order to quickly complete payment and signature.
You are entitled to control your Personal Information provided to TronLink.
3.1 You may import your other wallets into TronLink through synchronization of wallets and you may export your wallets from TronLink to other Tokens management wallets. TronLink will display the information of imported wallets to you.
3.2 You may add or delete Tokens, transfer and collect Tokens using the “Assets” column.
3.3 You understand that you may handle the following operations in the “Profile” column on TronLink:
3.3.1 in the “Settings” column, you may choose not to open “Touch ID/Face ID”, which means you may refuse to use the Touch ID/Face ID verification service;
3.3.2 in the “Feedback” column, you may submit any questions or suggestions for TronLink at any time. We are glad to communicate with you to improve our services.
3.4 You acknowledge that you may choose not to open “Payment without Password”, which means you may refuse to call your biological identification (Touch ID/Face ID) and authentication when conducting transactions.
3.5 You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.
3.6 Our Applications may contain links to other websites, applications or Smart Contracts that are not owned, operated, developed or maintained by us. These links are provided only for your convenience. This Policy only applies to our Applications. When using Third-Party Service, you understand that the TronLink Terms of Service and TronLink Privacy Policy will no longer apply. You are encouraged to carefully review their privacy policies and related terms of service.
3.7 You are entitled to ask us to update, revise, and delete your Personal Information and/or withdraw any consent provided to us. If you wish to withdraw any consent you have given us at any time, or if you wish to update, revise, delete or have access to your Personal Information held by us, or if you do not accept any amendment to this Policy, please contact us at:
Name: Ray Wu
Email: TronLink@tronlink.org
3.8 We may charge you a fee for responding to your request for access to your Personal Information held by us, or for information about the ways in which we have (or may have) used your Personal Information in the one-year period preceding your request. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received. We will endeavour to respond to your request within thirty (30) days, and if that is not possible, we will inform you of the time by which we will respond to you.
3.9 In many circumstances, we need to use your Personal Information in order for us to provide you with products or services that you require. If you do not provide us with the required Personal Information, or if you withdraw your consent to our use and/or disclosure of your Personal Information for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require.
4.1 We will keep your Personal Information for so long as we need the Personal Information for our business and legal purposes.
4.2 We do not sell, trade or otherwise transfer your Personal Information to third parties without your consent.
4.3 If you have consented to our disclosure of your Personal Information to our strategic business partners and associates, we may disclose your Personal Information to them. They will use your Personal Information only for the purposes you have consented to.
4.4 You agree that we may disclose or share your Personal Information with third parties such as:
4.4.1 service providers and data processors working on our behalf and providing services to us such as conducting know-your-clients checks, accounting, data processing or management services, website hosting, maintenance and operation services, e-mail message services, analysis services, handling of payment transactions, marketing etc; and
4.4.2 our consultants and professional advisors (such as accountants, lawyers, auditors).
4.5 If we need to transfer your Personal Information to any country for the purposes set out above, we shall obtain your prior consent and ensure that the recipient of the Personal Information protects your Personal Information to the same level as we have committed to protecting your Personal Information. Where these countries or territories do not have personal data protection laws that are comparable to the laws applicable to our relationship with you, we will enter into legally enforceable agreements with the recipients.
4.6 The Company will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:
4.6.1 the collected Personal Information is publicized by yourself;
4.6.2 the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;
4.6.3 in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities or to enforce our Policy or protect our or others’ rights, property or safety;
4.6.4 in the case of mergers and acquisitions, if transfer of Personal Information is involved, the Company may require the receivers of Personal Information to be continuously bound by this Policy.
5.1 We use Automatic Data Collection Technologies on our Applications. Examples of such technologies include:
5.1.1 Cookies (or browser cookies). Cookies are small text files which are set by a website or application operator so that your browser or device may be recognised. We may make use of cookies on our Applications to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analysing the usage of our Applications and to improve your online experience with us. You can disable the cookies by changing the setting on your browser. However, this may affect the functionality of the Applications.
5.1.2 Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and mobile applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and services our visitors are most interested in. The web analytics services on our Applications are provided by third-party service providers.
6.1 If the Company ceases operation, the Company will stop the collection of your Personal Information, and take steps to delete or anonymize your Personal Information held by us within a reasonable period.
6.2 To protect your Personal Information, the Company may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information.
6.3 We will send you messages about information security in the “Notifications” column and update articles concerning the use of wallets and information protection in the “Support” column on our Applications for your reference.
The following special provisions apply to minors who are under the age of 18 years old:
7.1 The minors shall not use TronLink without the guidance from their parents or guardians.
7.2 The parents and guardians of the minors shall provide guidance to the minors on using TronLink after they read this Policy, TronLink Terms of Service and other relevant rules.
7.3 TronLink will ensure the confidentiality and security of the minors’ Personal Information in accordance with the applicable laws and regulations.
8.1 After you use Third-Party Service, you acknowledge that this Policy no longer applies to the collection, use, disclosure and transfer of your Personal Information by these third parties. The Company is unable to guarantee that these third parties will implement reasonable security measures to protect your Personal Information.
8.2 You are solely responsible for your use of Third-Party Service and agree that you will not hold the Company liable for any damages incurred or injuries inflicted as a result of the collection, use, disclosure and transfer of your Personal Information by these third parties.
8.3 YOU ACKNOWLEDGE AND ACCEPT THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE COMPANY WILL ADOPT MEASURES AS REASONABLE AS POSSIBLE TO PROTECT YOUR PERSONAL INFORMATION UNDER CURRENT TECHNIQUES ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS, TO AVOID THE DISCLOSURE, TAMPERING OR DAMAGE OF INFORMATION. SINCE THE COMPANY TRANSFERS DATA WIRELESSLY, THE COMPANY MAKES NO GUARANTEE ON THE PRIVACY AND SECURITY OF WIRELESS INTERNET DATA TRANSFERRING.
9.1 You shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of the services provided by the Company.
9.2 Governing Law and Dispute Resolution:
9.2.1 This Policy shall be governed by and construed in accordance with the laws of People's Republic of China.
9.3 You may access this Policy and other terms (e.g. TronLink Terms of Service) through our Applications. We encourage you to check the TronLink Terms of Service and Policy of the Company each time you log onto our Applications.
9.4 Any translated versions of this Policy are provided for the convenience of Users, and are not intended to amend the original English version of this Policy. If there is any discrepancy between the English version and non-English version of this Policy, the English version shall prevail.
9.5 This Policy shall become effective on May 1, 2019.
Raybo (Beijing) Technology Co., Ltd.